Stay of administrative actions pending appellate determination of legality is within statutory revisional jurisdiction.

The petitioners filed a writ petition challenging orders dated 02.06.2026 and 28.07.2025 passed by the Commissioner, Sarguja Division (Respondent No. 2).

These orders arose from a revenue dispute where the Collector, Manendragarh, had previously declared certain land maps unauthorized, ordered the preparation of new maps, and directed the registration of FIRs and departmental inquiries against several revenue officials (including Respondent No. 4).

Respondent No. 4 appealed the Collector’s order to the Commissioner, who subsequently stayed the operation of the Collector’s directions.

The petitioners, having been impleaded as parties in the appeal, sought to vacate this stay.

The matter was brought before the High Court on the grounds that the issue was identical to a previous case involving the same petitioners.

1. Whether the Commissioner has the legal authority to stay an order passed by the Collector pending a revenue appeal.

2. Whether a stay order granted by a revenue authority should be vacated solely because it includes a stay on the registration of an FIR or departmental proceedings.

Section 44 of the Chhattisgarh Land Revenue Code, which provides for the right of appeal against the orders of revenue officers to superior authorities.

Section 52 of the Chhattisgarh Land Revenue Code, which expressly empowers the Commissioner to stay the effect and operation of an order passed by a Collector during the pendency of such proceedings.

The court observed that the core of the dispute—whether the maps prepared by revenue officials were illegal or utilized with malafide intent—is a finding that falls within the administrative and quasi-judicial purview of the Commissioner as the appellate authority.

The court reasoned that the Collector’s order was "premature" in its directions for criminal and disciplinary action until the Commissioner concluded the legality of the maps.

Applying Sections 44 and 52 of the Code, the court found that the Commissioner acted within his jurisdiction to maintain the status quo.

The court further noted that since the matter was still pending final adjudication before the Commissioner, any interference by the High Court at this interlocutory stage would be improper, regardless of the petitioners' contention that the registration of an FIR cannot be stayed.

The court dismissed the writ petition and granted liberty to the petitioners to pursue their case and arguments before the Commissioner in accordance with the law.